Connecticut Trust For Historic Preservation

Tax Credit Loans

The Connecticut Trust, a 501c3 non-profit, was chartered by the State of Connecticut in 1975 to protect and preserve Connecticut's significant buildings and landscapes.

To facilitate the preservation of historic buildings, the Connecticut Trust offers partnerships with developers who are utilizing the Connecticut state historic tax credits.

 

(Above Photo: Loom City Lofts in Rockville, on example of a project utilizing the CT Trust Tax Credit Loan)

The Connecticut Trust, with guidance from its staff, approves our involvement with projects through an executive committee made up of real estate developers, non-profit developers, tax attorneys.

The Connecticut Trust for Historic Preservation can be structured to receive the voucher (or accept as as a donation) from SHPO (or developer) at the end of the construction period, secure the funding from Eversource in exchange for the voucher, and either lend or grant 100% of the proceeds to the owner/LP/GP/manager, or other such mechanism that your tax counsel requires.

The Connecticut Trust is represented by Jim Scaramoza at MayoCrowe, Hartford, CT.

Structure:              

  • The CTHP is not providing tax advice and has no preferred structure. The Owner will structure the transaction as needed based on its tax counsel’s advice.

The CTHP has formed its own entity for this transaction, Historic Properties, LLC, referred to herein as the "CT LLC". The CT LLC will be considered a "disregarded entity" by the IRS and will take on the tax exempt status of its sole member, the CTHP.

Process:               

 The allocation of the CT Tax Credits and the flow of funds into the Project are anticipated to be as follows:

  • The Owner can allocate the entire CT Tax Credits to its managing member, (The "Managing Member").
  • The Managing Member can donate the entire CT Tax Credits to the CT LLC at or near the completion of construction to the Project, in accordance with donation agreement.
  • The CT LLC will sell the entire CT Tax Credits to Eversource, pursuant to a certain State Historic Tax Credits Purcahse and Transfer Contract (The "Purchase Contract")
  • The CT LLC will loan all of the proceeds from the sale of the CT Tax Credits to the Owner (the "Tax Credit Loan"), with an interest rate equal to 0.0% with a term of 40 years, with no payments due until maturity.
  • Other models can be considered.

Please contact Brad Schide, at circuitrider@cttrust.org  860-463-0193 for more information.

We look forward to working with you and thank you for your dedicated efforts to help preserve Connecticut’s architectural heritage.